ANNUAL ENVIRONMENTAL REPORT 2010The second most significant use of Energy is the electricity driven...

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ANNUAL ENVIRONMENTAL REPORT 2010

License Register Number P0826-01

License COOLEY DISTILLERY PLC

Location CASTLETOWN COOLEY

RIVERSTOWN

DUNDALK

COUNTY LOUTH

Report Year 2010

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Table of Contents

1.0 Introduction ................................................................................................................................. 3

1.1 Background to Cooley Distillery .......................................................................................... 3 1.2 Cooley Distillery Environmental Policy ................................................................................ 4 1.3 Cooley Distillery’s Organisation Chart for Environmental Management .............................. 5

2.0 Summary Information ................................................................................................................. 6

2.1. Emissions to Waters ............................................................................................................. 6-8 2.2. Emissions to Atmosphere ................................................................................................... 8 2.3. Ambient Monitoring ........................................................................................................... 8 2.4. Waste Management ..................................................................................................... 9-10 2.5. Resource Consumption ............................................................................................... 10-11 2.6. Environmental Incidents and Environmental Complaints .................................................. 12

3.0 Resource Efficiency .................................................................................................................... 14

3.1. Fuel Oil ................................................................................................................................. 14 3.2. Energy Efficiency .............................................................................................................. 14-14 3.3. Raw material efficiency in processes and the reduction in waste generated .......................... 15 3.4 Minimisation of water demand and the volume of trade effluent discharge ..................... 15

4.0 Environmental Management...................................................................................................... 16

4.1 Environmental Objectives & Targets 2010-2015 ................................................................ 16-16 4.2 Environmental Management Programme – 2010 Report .................................................. 17 4.3 Proposal for Environmental Management Programme – 2011.......................................... 19

5.0 Pollution Emission Register ................................................................................................... 19-21

6.0 License-Specific Reports ............................................................................................................. 23

6.1 Noise Monitoring ............................................................................................................. 23 6.2 Bund Integrity Assessments ............................................................................................. 23 6.3 Environmental Liabilities .................................................................................................. 24 6.4 Pollution Release and Transfer (PRTR) .............................................................................. 24 Bund 9- Spirit Store...................................................................................................................... 29 Effluent Sump .............................................................................................................................. 29 Emergency Pit.............................................................................................................................. 31

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1.0 Introduction

1.1 Background to Cooley Distillery

Cooley Distillery Plc. was issued an IPPC license by EPA on the 10th July 2008 (License Register

Number P0826-01). The activity is located at Castletown Cooley, Riverstown, Dundalk, Co.

Louth. The distillery is involved in the production of malt and grain whiskey using raw materials,

malted barley and IP (identity preserved) Maize. The manufacturing process comprises the

following main elements:

• A malt whiskey distillery with 4 fermenters & 2 stills; annual capacity 850,000 litres

alcohol;

• A grain whiskey still with 6 fermenters & 2 stills; annual capacity 2.8 million litres

alcohol;

• Bulk spirits warehousing and cask filling;

• Whiskey warehousing; capacity 33,000 casks;

• Bottling capacity of 2.4 million bottles per annum, and

• Services including steam boiler, cooling water system, waste water treatment plant,

laboratory and offices.

The distillery employs 47 staff and is operational for approximately 48 weeks of the year. The

normal hours of operation are 8.00 a.m. to 8.00 p.m. Monday to Saturday. Production is

continuous during this period. Occasionally, bottling operation, in particular, may be extended

to 9.00 pm. on Saturdays due to seasonal demand. The waste water treatment plant operates

on a continual basis.

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1.2 Cooley Distillery Environmental Policy

Cooley Distillery PLC is engaged in activities relating to the distillation and processing of alcohol

at its plant in Riverstown Dundalk Co. Louth. The organisation recognises its responsibilities to

its staff, shareholders, customers and the general public and is committed to the continual

improvement of the operating environment of its facilities.

To this end it will maintain a documented Environmental Management System which supports

its IPPC Licence P0826-01 and will take into account all regulatory and legislative requirements

pertinent to its sector, local operating environment and customer requirements.

The organisation’s environmental objectives include the following:

• Comply with all conditions of the IPPC Licence P0826-01.

• Creating a better environment for all, through the reduction, recycling and reuse of waste, the optimum usage of resources and the elimination of polluting releases to the environment.

• Compliance with all pertinent applicable regulations, legislation and licences.

• Prevention of pollution.

• Communicating its policies both internally and externally (regulators, customers, contractors and main suppliers) as appropriate.

• Commitment to continual improvement in environmental & business performance.

• Using the input of staff, customers, shareholders, government, local authorities, interested third parties and the general public.

• Awareness and training on environmental issues.

• Processing of ‘product’ in a safe and safe environment to customer specifications and requirements.

The above policy is supported by the management and directors of Cooley Distillery Plc who will

commit the necessary resources in ensuring that the objectives and targets can be achieved.

Appropriate programmes are set up to achieve our objectives and will be reviewed by

management.

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1.3 Cooley Distillery’s Organisation Chart for Environmental Management

The Environmental Team at Cooley Distillery is detailed below.

The following personnel are responsible for the overall environmental management of the

distillery and are the point of contacts in regard to the distillery’s environmental management:

1. Richard Dalton

2. Padraic Clear

3. Gabriel O’Loughlin

4. Noel Sweeney

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2.0 Summary Information The summary information provided below relates to the period 01st January 2010 to 31st

December 2010.

2.1. Emissions to Waters

SE1 Cooling Water

Cooling water discharge to the Piedmont River has no notable effects on the water quality. A

portion of the cooling water is discharged to the sea outfall in order to maintain sufficient flow

velocity in the pipeline to prevent seawater ingress. The annualised mass emissions from SE1

are summarised in Table 1 below.

Parameter Mass Emissions (Kg) 2010 Mass Emissions (Kg) 2009

Volume (m3) 294,432 252,479

BOD <851 <514

COD <1,914 <3,861

Suspended Solids <2,836 <1,534

Total Ammonia <8.5 <9.4

Copper 1.47 1.58

Table 1 Annualised mass of emissions from SE1

SE2 (Final Effluent from reed bed prior to mixing with cooling water)

The wastewaters from the process are organic in nature deriving as they do from cereals and

they are treated at an on-site wastewater treatment plant. Final effluent from the wastewater

treatment plant is diverted to a reed bed on site prior to mixing with cooling and the final

discharge to the Irish Sea. The annualised mass emissions of treated process effluent

discharged to sea compared with those given as the licensed Emission Limit Values (ELVs) are

presented in Table 2.

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Parameter Mass Emissions (Kg)

2010

Mass Emissions (Kg)

2009

Licensed Mass

Emissions (Kg/yr)

Volume (m3) 48,949 43,124 146,000m3

BOD 2,349 1,239 14600

COD 10,132 8,516 73000

Suspended Solids 1,860 1,235 7300

Total Ammonia 93 79 14600

Copper 9.8 7.9 73

Lead 0.12 0.2 29.2

Zinc 1.26 1.24 29.2


SE3 Combined effluent and cooling water discharge to the Irish Sea

The reed bed discharge and a portion of the cooling water are discharged to the sea outfall in

order to maintain sufficient flow velocity in the pipeline to prevent seawater ingress. The

wastewater is discharge to sea in Dundalk Bay, which is approximately 1 kilometre away. (Grid

reference: 317333E, 306042N.) The discharge is via a Cooley distillery owned long sea outfall

pipe. The discharge contains residual organic biodegradable contaminants at a concentration of

up to a license limit of 100 mg/l B.O.D. An extensive dispersion and biological study has been

carried out at the long sea outfall discharge point, which clearly demonstrates that the

wastewater is quickly dispersed to background levels and that no adverse biological impacts are

occurring. The annualised mass emissions from SE3 in 2010 are presented in Table 3 below.

Parameter Mass Emissions (Kg)

2010

Mass Emissions (Kg)

2009

Volume (m3) 69,098 85,695

BOD 5,113 2,210

COD 12,921 18,577

Suspended Solids 1,658 2,893

Total Ammonia 22 156

Copper 5.20 3.49

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Lead 0.12 0.31

Zinc 0.76 1.43


2.2. Emissions to Atmosphere

The principal sources and characteristics of emissions to atmosphere are CO2 from the four

malt and four grain fermenters and flue gas from the main oil fired process steam boiler (A1-1).

The license does not stipulate controls for any of these emissions to air. The main oil boiler is

required to be monitored annually for NOX and SOX, no mass emission limits apply. The annual

kg for NOX and SOX are summarised in Table 4 below.

Parameter Mass Emissions

(Kg/Annum) 2010

Mass Emissions

(Kg/Annum) 2009

Mass Emissions

(Kg/Annum) 2008

NOX 43,719 41,350 43,200

SOX 29,136 27,500 28,800

Table 4 Summary of emissions to atmosphere from steam boiler (A1-1)

2.3. Ambient Monitoring

2.3.1 Groundwater Monitoring

There are six groundwater monitoring locations required to be monitored as part of the licence.

Groundwater monitoring for S1-S4 was undertaken on 30/12/2010 while monitoring was

carried out at S5-S6 on the 03/02/11. The results are displayed in Table 5 below.

Parameter Units S1 S2 S3 S4 S5 S6

pH pH units 6.7 7.6 7.0 6.9 6.7 7.1

COD mg/l <5 <5 <5 <5 5 <5

Nitrate (as N) mg/l <0.272 1.330 0.550 1.260 7.250 6.750

Total Ammonia (as N) mg/l 6.96 0.289 0.107 <0.01 0.023 <0.01

Conductivity us/cm 629 392 774 532 572 499

Chloride mg/l 25.68 27.26 34.22 28.12 42.22 29.69

Table 5 Groundwater monitoring results 30/02/10

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2.4. Waste Management EWC Code

[1] HAZ [1] (y/n)

Description of waste [2]

Quantity [3] (Tonnes) in

2010

Quantity [4] (Tonnes) in

2009

Method of [5] Disposal/

Recovery

Location of [6] Disposal/

Recovery 200101 N Cardboard from

bottling 29.38 15.3 R5 Envirogreen

Recycling 200301 N Plastic from bottling 4.3 2.52 R5 Envirogreen

Recycling 200102 N Glass from bottling 10.52 9.32 R5 Dundalk, V&W

Recycling 200108 N Biodegradable

kitchen and canteen waste

9.5 10 D1 Oxigen Dundalk, Landfill

200303 N Street Cleaning Residues

5 4 D1 Oxigen Dundalk, Landfill

200301 N Mixed Municipal Waste from office and plant


200138 N Wood from broken pallets

1 20 R1&D1 Oxigen Dundalk, Landfill

190812 N Sludge from waste water treatment plant

1192.2 845.8 R10 -

020799 N Filter cake and sheets

5 6 D1 Oxigen Dundalk, Landfill

200202 N Soil and stones 0.1 2.25 D1 Oxigen Dundalk, Landfill

200201 N Grass, branches, pines


200121 Y Fluorescent tubes from lighting

0.015 0.015 R4&R5 Dundalk, V&W Recycling

130899 Y Waste oil water mixture

3 21.1 R1 Rilta Environmental

170106 Y Contaminated concrete

0 5.8 Rilta Environmental

Table 6 Waste record 2010

Waste efficiency trend 2010 and 2009

In 2010 42.34 tonnes was sent to landfill compared to 57.25 tonnes in 2009. This shows a

reduction of 26% in total waste sent to landfill. The trend in landfilled waste and sludge waste

efficiency in 2010 and 2009 is compared in Table 7.

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Waste efficiency trend parameter 2010 2009

Landfilled waste kg/litre of alcohol produced 0.0267 0.0342

Sludge waste kg/litre of alcohol produced 0.7525 0.5053

Table 7 Waste efficiency trend 2010 and 2009

There was a significant improvement in landfilled waste efficiency in 2010. However there was

a decrease in sludge waste efficiency when compared to 2009.

2.5. Resource Consumption

2.5.1 Energy

The main energy users on site are the Process Steam Boiler, which is fuelled with Medium Fuel

Oil (MFO). During the production process the main process water stream is raised to as high as

150oC during cooking, cooled to 63oC for mashing/conversion, cooled to 25oC for fermenting

and heated up to 100oC during distillation. The second most significant use of Energy is the

electricity driven fan on the MVR Evaporator. In the Evaporator 95% of the waste stream is

evaporated off. In a traditional multiple effect evaporator this would require some 20% of the

latent heat of evaporation. The MVR Evaporator uses about one quarter of this because the

evaporate itself is raised in temperature by the fan and its latent heat of condensation can then

be used to evaporate additional incoming spent wash.

Energy Consumption 2010 2009

Electricity (kW) 1,903,419 1,814,253

MFO (m3) 1,475 1,395

Table 8 Energy Consumption 2010

The electricity consumption increased by 89,166 kW in 2010 compared to 2009 which equates

to an overall increase of 4.9%. The MFO consumption increased by 80m3 in 2010 compared to

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2009 which equates to an overall increase of 5.7%. This is due to an increased level of alcohol

production in 2010 compared to 2009.

Energy Efficiency Trend 2010 2009

Electricity kW/litre of alcohol produced 0.934 0.955

MFO 2010 litres/litre of alcohol produced 0.724 0.833

Table 9 Energy efficiency trend 2010 and 2009

The per unit alcohol trend indicates a slight increase in energy efficiency. It is proposed that

energy efficiency trends will continue to be tracked. The per litre (MFO) alcohol trend shows a

modest increase in MFO efficiency of 14% when compared to 2009.

2.5.2 Water Consumption

Water usage at the site is used for process, cooling and minor miscellaneous use such as

domestic supply. The water usage is summarised in Table 10 below

Source 2010 (m3/annum) 2009 (m3/annum)

On site surface water 314,714 300,575

Municipal supply 3,646 3,343

Total 318,360 303,918

Table 10 Water consumption summary 2010 and 2009

In 2010 there was an increase in the total water consumption compared to 2009. Furthermore,

the water efficiency trend (see Table 11) improved significant due to the fact water new

fermenters with an improved cooling system were installed in 2009.

Water Efficiency Trend 2010 2009

Water m3/litre of alcohol produced 0.156 0.182

Table 11 Water efficiency trend 2010 and 2009

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2.6. Environmental Incidents and Environmental Complaints

2.6.1. Environmental Incidents

No major incidents (e.g. accidental release, spillages etc.) occurred during the year. However,

there were four exceedances of the emission limit values for BOD and COD at the reed bed

effluent discharge (SE2) in October and November 2010. A minor incident occurred during the

period 15th to 25th November 2010 where alcohol losses were incurred when re-distilling

product from spirit receivers 1 and 2 and VAT 4. This is believed to have caused the exceedance

at SE2 for BOD on 25th of November 2010. It should be noted that these breaches related to

non-toxic readily biodegradable aspects of the waste water. As such no adverse, or long-term,

environmental impacts would have resulted. Since the exceedances, the environmental

management team has put in place a number of corrective actions to prevent any further

exceedances. These include:

• Created and implemented an Environmental Management System.

• Hired a permanent qualified Environmental Technician.

• Created a Wastewater Treatment Plant Operation Manual.

• Installed a stand-by chemical precipitation system in clarifiers.

• Developed and implemented a system to prevent alcohol entering the WWTP.

• Cut down the turnaround time for results from our external laboratories.

• Circulating both internal and external results throughout the environmental team on a

weekly basis.

• Made a major upgrade in process control in distilling through the installation of a new PLC

SCADA automated process control system. The cost of this system was in excess of €150,000.

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• Doubled the number of instruments in the distilling process such as additional flow metres,

temperature controllers and level controls. All of these instruments are automatically controlled

by the new PLC control system.

There has been no repeat of the breach since it occurred in November 2010.

2.6.2 Environmental Complaints

No third party environmental complaints were received in 2010. Cooley Distillery has a formal

complaints procedure in place should any complaints of environmental nature arise.

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3.0 Resource Efficiency

3.1. Fuel Oil

The existing Process Steam Boiler, which is fuelled with Medium Fuel Oil was installed at the

distillery in 2007. The boiler is a Cochran Thermax 3 pass wet back design steam boiler. The

boiler has a steam output rating of 13,600 kg/hr. The boiler is fuelled with Medium Fuel Oil

(max 1% sulphur) with a maximum rate of burning of 867 kg/hr. The steam boiler operates

24 hours per day and 240 days per year.

The company contracted Rowan Engineering to carry out feasibility study for converting the

existing medium fuel oil fired boiler to light oil. The report was published on 28th of February

2011. The feasibility was assessed in terms of technical feasibility, suitability to the distilling

operations, economic feasibility and air emission aspects. The report states “ The boiler

modification will have a modest local environmental gain (in the absence of background air

pollution) at a prohibitive increase in boiler running costs (>50%)”.

Most importantly, the measured emissions from the process boiler at the distillery are

consistently within the required emission limits and it has already been demonstrated through

the results of the EPA specified air dispersion modelling exercise (that was performed as part of

the IPPC licence application) that this level of emission causes no adverse environmental impact

on local air quality. As the production of low emission fuels comes at an energy and emissions

cost (both incurred at the refinery) the use of such fuel can only be justified in the context of

resolving local air quality problems. In the demonstrated absence of any such local air quality

problems at Cooley it was concluded that there is no environmental justification for altering the

current boiler configuration.

3.2. Energy Efficiency

The principal energy source is the (medium fuel) oil fired boiler; this has a boiler rating of

13,600kg/hr of steam. The company are in the course of commissioning an energy audit of their

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facility by external energy consultants in 2011. Based on the findings of that audit it is intended

that any energy savings measures identified will be assessed and implemented where justified.

3.3. Raw material efficiency in processes and the reduction in waste generated

Ongoing monitoring of raw materials inputted to the processes is tracked against output

(alcohol) as part of the distilling operation. It is proposed as part of the EMP 2011 to carry out

internal waste auditing.

3.4 Minimisation of water demand and the volume of trade effluent discharge

Daily monitoring of water abstraction from the River Big was introduced in 2010 to accurately

monitor water abstraction in an effort to reduce consumption. Monitoring data collected by the

SCADA system was also carried out to ensure effluent discharge limits were adhered to.

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4.0 Environmental Management

4.1 Environmental Objectives & Targets 2010-2015 Objectives Date Targets

Full IPPC licence compliance

2010- 2015 Consistent IPPC adherence by means of: • Ongoing internal environmental audits. • Regular environmental team meetings. • Strive towards to continual environmental improvement.

WWTP performance parameters to adhere to IPPC licence Emission Limit Values (ELV’s)

2010- 2015 Consistent IPPC adherence by means of: • Daily WWTP checks by WWTP operators. • Investigate the potential for WWTP improvements.

Zero Environmental Complaints

2010-2015 To continue to stay complaint free by means of: • Open communications with neighbours. • A formal environmental complaints procedure is in place

as part of the distillery’s EMS. Review all operations and processes with regard to resource optimisation

2010-2015 Resource Management : • Energy • Resource efficiency • Cleaner technology • Cleaner production • Prevention, reduction and minimisation of waste • Minimise the volume of non-contact cooling water

returned to the River Big. Fugitive emissions 2010-2015 Identification & reduction of fugitive emissions using best available

techniques

Electricity Usage 2010-2015 Reduce electricity consumption by 5% per unit by 2015 based on the 2009 baseline of 0.955 kW/ litre of alcohol.

• Internal and external energy auditing. • Put in place internal departmental metering and targeting

for electricity consumption. Fuel Oil Usage 2010-2015 Reduce fuel oil consumption by 5% per unit by 2015 based on the

2009 baseline of 0.833 litres/ litre of alcohol. • Internal auditing of fuel oil usage. • Put in place metering and targeting for fuel oil

consumption. Water Usage 2010-2015 Reduce water consumption by 5% per unit by 2015 based on the

2009 baseline of 0.182 m3 / litre of alcohol. • Internal water auditing. • Put in place internal departmental metering and targeting

for water consumption. Reduce the amount of 2010-2015 Reduce the amount of waste generated by 10% per unit by 2015

based on the 2009 baseline of 0.0357 kg / litre of alcohol.

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waste sent to landfill

Night time noise 2010-2015 Continue to endeavour to reduce night time noise beyond the boundary of the distillery. Note no noise complaints have been by the distillery to date

4.2 Environmental Management Programme – 2010 Report

Objective No 1 Optimise Process Operation and Control Target Action Responsibility Start

Date Finish Date

Optimise usage of process raw materials .

Assess the efficiency of the use of raw materials. Compliance Manager

Ongoing Ongoing

Track key performance indicators (KPI’S) which relate raw materials usage and waste generated to units of production

Compliance Manager

Ongoing Ongoing

2010 Progress Annual monitoring and KPI in place in 2010 for waste. No KPI for raw materials. No internal raw material/waste audit carried out to date.

Compliance Manager

Status: Ongoing

Objective No 2 Improve Waste Management Target Action Responsibility

Start Date

Finish Date

Improve landspread waste management Establish waste tracking programme within the

draft EMS

Compliance Manager

Aug-08 Ongoing

Reduce the quantity of general office and factory waste arising

Ensure adequate waste segregation and collection facilities are available throughout the plant

Compliance Manager

Aug-08 Ongoing

Raise staff awareness of the need for waste reduction.

Compliance Manager

Aug-08 Ongoing

2010 Progress Tracking programme in place for landspread organic waste. No internal waste auditing conducted in 2010. Environmental awareness training undertaken in 2010.

Compliance Manager

Status: Ongoing

Objective No 3 Minimise emissions to the environment Target Action Responsibility Start Date Finish Date

Improve the management of waste water treatment

Daily C.O.D. & T.S.S. monitoring Compliance Manager May-09 Ongoing

2010 Progress Daily COD & T.S.S. monitoring undertaken. Compliance Manager Status: Ongoing

Ensure the integrity of bunded areas

Conduct integrity tests of all tank bunds. Compliance Manager Jul-09 Dec-10

2010 Progress All bunds integrity tested by independent engineers. The final 3 bunds passed integrity testing.

Compliance Manager Status: Ongoing

Ensure appropriate disposal of bund content

Confirm bund content are uncontaminated before disposal

Compliance Manager Ongoing Ongoing

2010 Progress Conducted in 2010 Compliance Manager Status: Ongoing

Contain any spillages from loading/unloading areas.

Investigate drainage arrangements and containment options at loading/unloading areas

Compliance Manager Jul-09 Dec-10

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2010 Progress Completed in 2010 Compliance Manager Status: Closed

Ensure no leakages from pipes and valves

Weekly visual inspection

Compliance Manager Aug-08 Ongoing

2010 Progress Been conducted Compliance Manager Status: Ongoing

Minimise medium fuel oil boiler emissions to atmosphere

Continue boiler efficiency monitoring regime Compliance Manager Continuing Continuing

2010 Progress Been carried annually as part of licence requirements


Conduct a feasibility study into the use of an alternative fuel source to mixed fuel oil

Conduct a feasibility study into the use of gas oil in the process steam boiler

Compliance Manager Completed 28th February 2011

2010 Progress Been conducted Compliance Manager Status: Closed

Reduce noise emissions from the site

Carry out annual noise surveys and address issues which arise from the noise surveys

Compliance Manager Aug-08 Ongoing

2010 Progress Noise monitoring carried out in April 2010. No noise related complaints from any third parties to date.


Ensure no risk of water pollution from fire-water

Undertake fire-water retention study

Compliance Manager Aug-09

Feb-11

2010 Progress Rowan Engineering appointed as consultant. It is envisaged that this report will be completed in March 2011.


Establish a risk management programme (based on outcome of above)

Compliance Manager Aug-09 Feb-11

2010 Progress Ongoing Compliance Manager Status: Ongoing

Objective No 4 Optimise energy efficiency and utility usage Target Action Responsibility Start Date Finish Date

Reduce energy consumption Commission an energy audit of the site Compliance Manager Jul-09 Dec-10

Progress 2010 No energy audit commissioned in 2010. Compliance Manager Status: ongoing

Objective No 5 Improve the Environmental Management of the Site Target Action Responsibility Start Date Finish Date

Provide an appropriate number of spill kits around the distillery

Review current spill kit locations and place additional spill kits in wheelie bins if deemed necessary

Compliance Manager Apr-10 Aug-10

Progress 2010 A three spill kits have been positioned around the facility

Compliance Manager Status: Closed

Ensure appropriate (environmental) data management

Appoint an external EMS consultant Compliance Manager Oct-08 Oct-09

Progress 2010 Environmental data management is being filed internally.

Compliance Manager Status: ongoing

Label all tanks and drum Identify and suitably label all tanks and drums (incl. Whiskey warehouse)

Compliance Manager Oct-08 Aug-10

Progress 2010 Tanks and drums fully labelled. Compliance Manager Status: Complete

Ensure accuracy of monitoring data

Source and use certified laboratories Compliance Manager Ongoing Ongoing

Progress 2010 External monitoring is carried out by accredited laboratories.

Compliance Manager Status: ongoing

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Ensure accuracy of flow discharge values

Recalibration and maintenance of process water and cooling water discharge flow meters

Maintenance Manager Ongoing Ongoing

Progress 2010 All flow meters are checked monthly Maintenance Manager Status: ongoing

Protection of the marine environment

Source suitable supplier for marine monitoring Compliance Manager Completed 10/7/2013

Progress 2010 To be completed Compliance Manager Status: ongoing

Objective No 6 Risk Management Target Action Responsibility Start Date Finish Date

Reduce risk of environmental legacies

Establish a Decommissioning Plan framework Compliance Manager Oct-09 Dec-10

Progress 2010 Rowan Engineering complied a DMP in 2009 Compliance Manager Status: ongoing

Meet costs of any future environmental liabilities

Establish Environmental Liabilities cover Financial Manager Jul-09 Dec-10

Progress 2009 Pollution insurance cover is in place Financial Manager Status: ongoing

4.3 Proposal for Environmental Management Programme – 2011 Target Action Responsibility Timeframe

Full compliance in 2010 with the Distillery’s IPPC licence

Consistent IPPC adherence by means of: • Ongoing internal environmental audits. • Regular WWTP meetings with Compliance

Manager and WWTP operators. • Strive towards to continual environmental

improvement.

Environmental Team 2011

WWTP performance parameters to adhere to IPPC licence Emission Limit Values (ELV’s)

Consistent IPPC adherence by means of: • Daily WWTP checks by WWTP operators. • Put in place WWTP SOP • Investigate the potential for WWTP

improvements. • Regular consultation with REC.


Zero Environmental Complaints Continue open communications with neighbours. Environmental Team 2011

Reduce electricity consumption by 1% per unit based on the 2009 baseline of 0.955 kW/ litre of alcohol.

• Internal and external energy auditing. • Put in place internal departmental

metering and targeting for electricity consumption.

• During resource meetings assess electricity consumption.


Reduce fuel oil consumption by 1% per unit based on the 2009 baseline of 0.833 litres/ litre of alcohol.

• Internal auditing of fuel oil usage. • Put in place metering and targeting for

fuel oil consumption. • During resource meetings assess fuel oil

consumption.


Reduce water consumption by 1% per unit based on the 2009 baseline of 0.182 m3 / litre of alcohol.

• Internal water auditing. • Put in place internal departmental

metering and targeting for water consumption.


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• During resource meetings assess water consumption.

Reduce the amount of waste sent to landfill by 2% based on the baseline 57.25 tonnes (or 0.034 kg/litre of alcohol) in 2009

• Internal waste auditing to identify options for waste prevention, minimisation, recycling and recovery.

• During resource meeting review waste volumes generated and disposed.


Improve the environmental training of the Environmental Team

• Rowan Engineering to conduct environmental training of the key environmental personnel.

• Certificates to be retained in the training file.

Environmental Team By May 2010

Fugitive emissions • Identify the fugitive emissions associated with the distillery.

• Evaluate the potential/feasibility to eliminate or reduce these emissions.


Night time noise Continue to endeavour to reduce night time noise beyond the boundary of the distillery. Note no noise complaints have been by the distillery to date.


5.0 Pollution Emission Register Cooley Distillery’s IPPC licence requires that they prepare a proposal for a Pollution Emission

Register (PER). The list of substances to be included in a PER is specified by the EPA in their AER

Guidance Note. Cooley Distillery has compared the materials emitted from the facility with that

EPA PER materials candidate list. Based on that comparison the materials considered relevant

for inclusion in the annual PER returns are the following:

Total Nitrogen, Total Phosphorus and CO2under the heading of “Environmental Themes”

and Copper under the heading of “Heavy Metals”.

Both the Total Nitrogen (N) and Total Phosphorus (P) and are derived from the primary raw

material (grain). The vast majority of the N and P arises as an emission within the sludge

generated by the wastewater treatment plant and in the treated wastewater discharge. The

treated wastewater is discharged to sea and the excess wastewater sludge is landspread as a

fertilizer.

Carbon Dioxide (CO2) arises from the fermentation process that converts sugars to ethanol.

The CO2 arising is vented to atmosphere. As the CO2 is derived from the cereals grown for the

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alcohol production it is, from a climate change perspective, carbon neutral in that the CO2

release from the production process equals that absorbed from the atmosphere by the cereal

grown to meet the facilities raw material requirements. CO2 also arises from the main process

boiler.

Copper is derived from the leaching of low levels of copper from the distillation units and is

discharged to sea as a minor contaminant within the treated wastewater, some small residual

copper may be accounted for in the wastewater treatment plant sludge.

Materials Requiring Full PER

Given the very low quantities of copper and the low and the non-persistent nature of the N, P

and CO2 it is not proposed to carry out a full PER in respect of any of these emissions. The

proposed timeframe for each is twelve months.

Proposed Methodology

With the exception of CO2 the PER for each parameter will be based on measured

concentration values and the corresponding recorded annual volumes/tonnages.

CO2 is derived from fermentation and the burning of oil and can be calculated as follows:

In the case of fermentation, CO2 and ethanol are produced in equimolar quantities and the

quantity of CO2 relative to ethanol is the same as the ratio of their molecular weights (44:46).

Therefore knowing the annual production of ethanol the corresponding CO2 value can be

reliably derived. In the case of the boiler the CO2 emissions can be calculated from the carbon

content of the known quantity of fuel consumed in any given year.

Summary

A review of the criteria set by the EPA for PER indicates that the materials to be recorded

annually at Cooley Distillery are:

Total N, Total P, Copper, and CO2

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PER Report 2010

PARAMETER Total Output 2010 tonnes

Air Land Water (Sea)

CO2 6,612 Boiler: 4,723 MT Fermenters: 1,889 MT

- -

Total Nitrogen

5.317 - Landspread: 5.317MT -

Total Phosphorus

0.942 - Landspread: 0.942MT -

Copper 0.221 - Landspread: 0.206MT SE2:0.0098 SE3:0.0052

Proposal 2011

It is proposed that the same methodology and parameters tracked in 2010 will be used for the PER

Report 2011.

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6.0 License-Specific Reports

6.1 Noise Monitoring

A noise survey was completed by Rowan Engineering Consultants on the 08th April 2010. A

summary of the noise monitoring results is provided in Table 12 below. To date, Cooley Distillery

has not received any noise related complaints from any third parties.

Monitoring

Period

LAeq dB(A) (30

mins)

LA10 dB(A) LA 90 dB(A)

NSL1 Day 54 56 52

NSL1 Night 55 55 54

NSL2 Day 54 56 50

NSL2 Night 48 49 46

NSL3 Day 58 56 50

NSL3 Night 54 50 48

B1 Day 55 59 49

B2 Day 69 71 68

B3 Day 58 59 57

B4 Day 53 55 49

B5 Day 47 49 43

Table 12 Noise monitoring results 08/04/10

6.2 Bund Integrity Assessments

A number of bund integrity assessments were carried out by Rowan Engineering Consultants in

2010. Following the bund integrity assessments the majority of bunds passed the hydrostatic

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tests. Copies of the bund test summary sheets are enclosed as part of Appendix 2 to this report.

A copy of the full bund test reports including maps and photographs are retained on site and

are available for inspection.

6.3 Environmental Liabilities

The potential environmental liabilities associated with the Cooley Distillery were assessed in

2010 by Rowan Engineering Consultants who completed an Environmental Liabilities Risk

Assessment (ELRA) and the Decommissioning Management Plan (DMP) on behalf of Cooley

Distillery.

These reports were forward to the Agency in February 2010. Cooley Distillery has

environmental pollution cover for €6.25 million with Hibernian Insurance. Due to the fact that

the ELRA and DMP were recently carried out and that there have been no significant on site

changes a review is not necessary as part of this AER.

6.4 Pollution Release and Transfer (PRTR)

A PRTR was submitted to the Agency in 2010. A copy of the 2010 PRTR/AER return is included

as an appendix to this report and it has also been submitted to the Agency.

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26

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Bund 9- Spirit Store Company: Cooley Distillery IPPC Ref. No.: P0826-01 Bund Reference Number: Bund 9

Bund Location: Front yard- spirit store compound

Bund Dimensions: 13.7 long * 15m wide * 1.36m high =279.5 m3 & 16.7m long * 12.4 wide *1.36m high =281.6m3 Total= 561 m3 = 561,000 litres

Primary Vessels (s)- Material of Construction: 6 No. steel tanks elevated in the bund.

Bund Material of Construction: The bund is concrete block lined with resin. The floor of the bund is constructed with mass concrete.

Primary Vessels (s)- Total Storage Volume: 6 No. tanks approx. 100,000 litres = 600,000 litres

Primary Vessels (s)- 110% of Volume of the largest vessel: = 110,000 litres

Primary Vessels (s)- 25% of the Total Storage Volume: = 150,000 litres

Deemed safe/practicable to carry out a hydrostatic test? YES NO If no, detail reasoning: Description & results of the visual inspection Date of the visual inspection No visual evidence of potential bund failure was recorded.

29/12/2010

Description & results of hydrostatic Test: Date of hydrostatic Test: 24 hour Test The bund was filled to a mark 0.398m from the floor of the bund. This was allowed to stabilise 24 hour stabilisation period on the 29/12/10. The water level was checked on 30/12/10 and the 31/12/10. The results of the 24 hour test are displayed below.

Date Average Level below top of bund wall

30/12/2010 0.398m 31/12/2010 0.398m

30/12/2010 to 31/12/2010 No drop in the water level was recorded during the test. Reference Vessel

Date Water level to top of vessel

30/12/2010 193mm 31/12/2010 193mm

RESULT OF HYRODROSTATIC TEST- PASS/FAIL PASS Recommendations: It is recommended that the Spirit Store Bund is retested by December 2013.

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Effluent Sump

Company: Cooley Distillery IPPC Ref. No.: P0826-01 Bund Reference Number: Effluent Sump

Bund Location: Beside evaporator

Bund Dimensions: 4.6mlong * 1.15m wide * 1.47m high = 7.8m3

Primary Vessels (s)- Material of Construction: N/A

Bund Material of Construction: The bund is concrete block lined with concrete.

Primary Vessels (s)- Total Storage Volume: N/A

Primary Vessels (s)- 110% of Volume of the largest vessel: N/A

Primary Vessels (s)- 25% of the Total Storage Volume: N/A

Deemed safe/practicable to carry out a hydrostatic test? YES NO If no, detail reasoning: Description & results of the visual inspection Date of the visual inspection No visual evidence of potential bund failure was recorded. 29/12/2010 Description & results of hydrostatic Test: Date of hydrostatic Test: 24 hour Test The pump to the balance tank at WWTP was switched off. The sump was filled to a mark 1.08m at the top of the overflow wall on the 29/12/10. This was allowed to stabilise 24 hour stabilisation period on the 29/12/10. The water level was checked on 30/12/10 and the 31/12/10. The results of the 24 hour test are displayed below.

Date Average Level below top of bund wall

30/12/2010 1.08m 31/12/2010 1.08m



30/12/2010 193mm 31/12/2010 193mm

RESULT OF HYRODROSTATIC TEST- PASS/FAIL PASS Recommendations: It is recommended that the Effluent Sump is retested by December 2013. In addition, the Effluent Sump should be labelled.

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Emergency Pit

Company: Cooley Distillery IPPC Ref. No.: P0826-01 Bund Reference Number: Emergency Pit & channel

Bund Location: Beside Syrup Store

Bund Dimensions: 23.6m long* 4.05m wide* 1.83m deep = 175m3 & channel from effluent sump which drains into the emergency pit is: 19.35mlong * 1.15m wide * 1.6m high = 35.6m3 Total = 210m3

Primary Vessels (s)- Material of Construction: N/A

Bund Material of Construction: The bund and channel is concrete block lined with concrete.

Primary Vessels (s)- Total Storage Volume: N/A

Primary Vessels (s)- 110% of Volume of the largest vessel: N/A

Primary Vessels (s)- 25% of the Total Storage Volume: N/A

Deemed safe/practicable to carry out a hydrostatic test? YES NO If no, detail reasoning: Description & results of the visual inspection Date of the visual inspection No visual evidence of potential bund failure was recorded.

29/12/2010

Description & results of hydrostatic Test: Date of hydrostatic Test: 24 hour Test The bund was filled to a mark 1.98m from the top of the bund at its high side and 0.82m at its low side. The channel was filled to 1.19m at the overflow wall with the effluent sump. This was allowed to stabilise 24 hour stabilisation period on the 29/12/10. The water level was checked on 30/12/10 and the 31/12/10. The results of the 24 hour test are displayed below.

Date Overflow wall in channel

To top of bund (High end of pit)

To top of bund (Low end of pit)

30/12/2010 1.08m 1.98 0.82 31/12/2010 1.08m 1.98 0.82



30/12/2010 193mm 31/12/2010 193mm

RESULT OF HYRODROSTATIC TEST- PASS/FAIL PASS Recommendations: It is recommended that the Emergency Pit is retested by December 2013. In addition, the Emergency Pit should be labelled.

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